Requests for Production of Documents to a Loan Servicer for a Trustee of a Mortgage-Backed Securities Fund

These are sample requests to be served on a loan servicer in an action in which there are issues regarding the accounting of the mortgage loan such as the proper crediting of payments, charging of unnecessary or excessive fees, and failure to negotiate a loan modification prior to foreclosure.

PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 1 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Cameron H. Totten, Esq. (SBN 180765) Law Offices of Cameron H. Totten 620 N. Brand Blvd., Ste. 405 Glendale, California 91203 Telephone (818) 483-5795 Facsimile (818) 230-9817 ctotten@ctottenlaw.com Attorney for Plaintiffs SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES PLAINTIFFS, vs. SPECIALIZED LOAN SERVICING, LLC; MTC FINANCIAL INC., DBA TRUSTEE CORPS; U.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.;; ALL PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFFS’ TITLE, OR ANY CLOUD ON PLAINTIFFS’ TITLE THERETO; and DOES 1-20, INCLUSIVE, DEFENDANTS. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SPECIALIZED LOAN SERVICING, LLC PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 2 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: PROPOUNDING PARTY: PLAINTIFF RESPONDING PARTY: DEFENDANT SPECIALIZED LOAN SERVICING, LLC. Plaintiff (“Plaintiff”) hereby requests that Defendant SPECIALIZED LOAN SERVICING, LLC (“Defendant” or “YOU”) produce the following items, papers, documents and materials now in YOUR possession or under YOUR control and to permit the reproduction of the originals thereof (or copies if the originals cannot be produced) pursuant to CCP Section 2031.010 et seq. The items hereinafter requested shall be produced at 10:00 a.m., on, at 620 N. Brand Blvd., Ste. 405, Glendale, CA 91203. INSTRUCTIONS FOR COMPLIANCE WITH THIS REQUEST A. As used throughout this set of requests, the term “writing” refers to papers, books, records, files, letters, memoranda, contracts, invoices, change orders, photostatic copies, magnetic or electrical impulse or any other form of communication is recorded or reproduced and includes anything covered by Section 250 of the California Evidence Code. B. The term “document” or “documents” shall mean all written or graphic materials, however produced or reproduced, in your actual or constructive possession, care, custody or control or of any of the officers, directors, representatives, members, agents or employees of their related corporations, enumerated under “documents requested,” including but not limited to files, letters, contracts, agreements, telegrams, memoranda, notes, reports, applications, correspondence, sound recordings or tapes of any conversation or meeting or conference, minutes of meetings, handwritten memorandums or notes, interoffice communications, summaries, logs, or any other printed, typewritten or handwritten material of any nature similar to the foregoing, however denominated, including all drafts and carbon or photographic copies of any such material. C. The term “Subject Property” shall mean the property commonly known as. D. The listing of any specific document or writing or categories of documents or writings following any general request herein shall be solely by way of example and shall not be deemed to limit the generality of any such request. E. The request for any documents or writings which relate or refer to any subject shall be deemed to request any document or writing which deals with, relates to or refers in any way whatsoever, either directly or indirectly, to that subject. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 3 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 F. In complying with this request, you are required to furnish all the items asked for which are available to you. This would include items in the possession or control of other persons directly or indirectly employed by, or connected with, you or your attorney or your insurance carriers or anyone subject to your control of anyone else acting in your behalf. G. In complying with this request, you must make a diligent search of the records, papers, and materials in your possession or available to you. H. In any requested document or writing is known to have existed by no longer exists or is no longer in your possession or control, identify its last known custodian and state the date upon which it was lost or destroyed or became unavailable, or if the document or writing still exists, identify its present custodian and location. I. If you cannot obtain the requested items in time to comply with this request, you may ask for an extension of time, explaining the circumstances and explaining what is being done to obtain the requested items. J. If you can only produce copies but not originals, you must provide an explanation as to the absence of the originals. K. If privilege is claimed as to any requested document or writing, state the author or recipient of said document, the date of said document or writing, describe the nature of the document or writing, and specify the privilege claimed. REQUESTS FOR PRODUCTION OF DOCUMENTS REQUEST FOR PRODUCTION NO. 1: All documents which establish that U.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE was the legal, beneficial or equitable owner of the promissory note that is the subject of this action at the time of the non-judicial foreclosure of the Subject Property. REQUEST FOR PRODUCTION NO. 2: The original promissory note signed by Plaintiffs in this matter. REQUEST FOR PRODUCTION NO. 3: A copy of the original promissory note signed by Plaintiffs in this matter. REQUEST FOR PRODUCTION NO. 4: All Powers of Attorney for any person signing any of the documents requested herein. REQUEST FOR PRODUCTION NO. 5: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 4 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All documents that purport to grant authority to any person to sign any of the documents referred to herein. REQUEST FOR PRODUCTION NO. 6: The notary registration book for any public notary who certified the signature of any person on any document referred to herein. REQUEST FOR PRODUCTION NO. 7: All documents that establish U.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE standing to foreclose on the Subject Property, including but not limited to: A. Copies of all contracts, documents, agreements and other disclosure forms, written communications, notes, memoranda and records concerning the note and mortgage that are the subject of this action, including attorney fee contracts. B. Copies of all receipts for payments made by or to and/or received by YOU concerning the note and mortgage that are the subject of this action. REQUEST FOR PRODUCTION NO. 8: All documents that establish the identity of the servicer of Plaintiffs’ mortgage loan that is the subject of this action. REQUEST FOR PRODUCTION NO. 9: All contracts between YOU and any person or entity regarding the servicing of the deed of trust and/or note at issue in this matter. REQUEST FOR PRODUCTION NO. 10: All assignments, transfers, allonge, or other documents evidencing a transfer, sale or assignment of Plaintiffs’ note, deed of trust, monetary instrument or other document that secured payment by Plaintiffs of the loan at issue in this matter from the inception of the mortgage loan to the present date including any such assignment on MERS. If none, state “none”. REQUEST FOR PRODUCTION NO. 11: All electronic transfers, assignments and sales of Plaintiffs’ note/asset, mortgage, deed of trust or other security instrument. REQUEST FOR PRODUCTION NO. 12: All original and intervening Assignments showing a complete chain of assignments from the originator to the person assigning the deed of trust and note to U.S. BANK NATIONAL PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 5 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE. REQUEST FOR PRODUCTION NO. 13: All original and intervening receipts of delivery and acceptance of each note showing a complete chain of such receipts from the originator to the person accepting the document for U.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE. REQUEST FOR PRODUCTION NO. 14: All original and intervening endorsements showing a complete chain of endorsements from the originator to the person endorsing Plaintiffs’ note to U.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE. REQUEST FOR PRODUCTION NO. 15: All documents relating to the transfer and assignment of Plaintiffs’ deed of trust and promissory note from the originator of the underlying mortgage note to the depositor for the securitized trust known as THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE Trust ("the Trust") so as to show a complete chain of transfers and assignments from the originator to the person so endorsing to U.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE (the Trustee for the Trust). REQUEST FOR PRODUCTION NO. 16: All documents relating to the endorsement and delivery of Plaintiff’s mortgage note from the originator there to the depositor for THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE Trust ("the Trust") so as to show a complete chain of endorsements and signed delivery receipts from the originator to the person so endorsing to U.S. BANK NATIONAL ASSOCIATION AS INDENTURE TRUSTEE, ON BEHALF OF THE HOLDERS OF THE PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 6 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE (the Trustee for the Trust). REQUEST FOR PRODUCTION NO. 17: All documents relating to the endorsement and delivery of Plaintiffs’ mortgage note from the depositor for THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE Trust ("the Trust") to the Trustee for the Trust or YOU so as to show a complete chain of endorsements and signed delivery receipts from the depositor for the Trust to the Trustee for the Trust. REQUEST FOR PRODUCTION NO. 18: All documents which relate to, refer to or evidence any and all electronic transfers, assignments and sales of the note or asset, mortgage, deed of trust or other security instrument. If none, state “none”. REQUEST FOR PRODUCTION NO. 19: All documents (including all computer or digital media-stored data) relating to Plaintiffs, the Subject Property, and the subject transaction and/or account, or which are indexed, filed or retrievable under their name or any number, symbol, designation or code (such as a transaction number or Social Security number) assigned to them or to the subject transaction(s), including but not limited to all documents relating to the origination, approval, disbursement, assignment and administration of the loan(s), all agreements, and all correspondence related to the subject transaction. REQUEST FOR PRODUCTION NO. 20: All documents relating or referring to YOUR policy and practice relating to the origination, approval or underwriting, preparation, disbursement and acceptance of assignment of a residential mortgage loan such as the subject transaction(s), including but not limited to all agreements with brokers, lenders, title companies, assignors, etc.; and all instructions, policy and procedure manuals, memoranda and guidelines given to brokers, title companies, lenders, closing agents, and/or any persons who review account files for approval and/or acceptance of assignment. REQUEST FOR PRODUCTION NO. 21: All documents, records and transaction books maintained by YOU for the mortgage loan at issue in this matter. REQUEST FOR PRODUCTION NO. 22: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 7 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All correspondence by and between YOU and either of the Plaintiffs to this action. REQUEST FOR PRODUCTION NO. 23: All correspondence by and between YOU and any Defendant to this action with regard to the subject mortgage loan. REQUEST FOR PRODUCTION NO. 24: All sales contracts, servicing agreements, assignments, allonges, transfers, indemnification agreements, recourse agreements and any agreement related to this account from the inception of this account to the present date. REQUEST FOR PRODUCTION NO. 25: The outside and inside front and back of the file folder for Plaintiffs’ loan account. REQUEST FOR PRODUCTION NO. 26: The entire loan file related to Plaintiffs’ loan for the Subject Property. REQUEST FOR PRODUCTION NO. 27: All documents and records, electronic or otherwise, of assignments of this mortgage, monetary instrument or servicing rights to this mortgage including any such assignments on MERS. REQUEST FOR PRODUCTION NO. 28: The Federal National Mortgage Association (Fannie Mae), Federal Home Loan Mortgage Corporation (Freddie Mac), Housing and Urban Development (HUD) Family Servicing Guidelines or any other servicing guidelines used for the servicing of Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 29: The Investor Loss Mitigation and Loan Modification Guidelines related to Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 30: All documents recording, reflecting or otherwise relating to visits which YOU or YOUR agents made to the Subject Property. REQUEST FOR PRODUCTION NO. 31: All account servicing transaction records, ledgers, registers and similar items detailing how Plaintiffs’ account has been serviced from the inception of the account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 32: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 8 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All letters, statements and documents sent to YOU by previous servicers, sub-servicers or others in the account file. If none, state “none”. REQUEST FOR PRODUCTION NO. 33: Each and every canceled check, money order, draft, debit or credit notice issued to any servicers of Plaintiffs’ account for payment of any monthly payment, other payment, escrow charge, fee or expense on the account. If none, state “none”. REQUEST FOR PRODUCTION NO. 34: All account servicing records, payment payoffs, payoff calculations, ARM audits, interest rate adjustments, payments records, transaction histories, account histories, accounting records, ledgers, and documents that relate to the accounting of Plaintiffs’ account from the inception of the account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 35: All data, information, notations, text, figures and information contained in your mortgage servicing and accounting computer systems including, but not limited to Alltel or Fidelity CPI system, or any other similar mortgage servicing software used by you, any servicers, or subservicers of Plaintiffs’ mortgage account from the inception of Plaintiffs’ account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 36: All descriptions and legends of all Codes used in YOUR mortgage servicing and accounting system so as to enable the examiners and auditors and experts retained to audit and review this mortgage account to properly carry on their work. If none, state “none”. REQUEST FOR PRODUCTION NO. 37: All account servicing transaction records, ledgers, registers and similar items detailing how Plaintiffs’ account was serviced from the inception of the account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 38: All records for any custodial accounts used for any purpose in connection with Plaintiffs’ mortgage loan including the date, amount and source of all deposits in such accounts and the date, amount and purpose for all disbursements including the name and address of any party who received any such disbursement. REQUEST FOR PRODUCTION NO. 39: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 9 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All documents and records related to all servicer advances made by any servicer of Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 40: All documents and records related to all non-recoverable advances made by any servicer of Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 41: A complete and itemized statement from the date of the origination of Plaintiffs’ loan to the present of any fees incurred to modify, extend, or amend the loan or to defer any payment due under the terms of the loan. REQUEST FOR PRODUCTION NO. 42: All collection notes, reports, memos, statements, entries, data records, computer records, daily records, calendar reports, default reports, collection contacts, collection reports or other documents generated in connection with the servicing of Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 43: All documents which relate to, refer to or evidence any and all civil actions, adversary proceedings, arbitrations, or administrative proceedings that have been filed against YOU at any time in the past 60 months for any alleged misconduct related to mortgage servicing or foreclosures. REQUEST FOR PRODUCTION NO. 44: Any and all correspondence, transfers, documents to or from Fannie Mae and/or Freddie Mac in connection with Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 45: Any and all letters, statements and documents contained in Plaintiffs’ account file or imaged by YOU, any servicers or sub-servicers of the mortgage from the inception of the account to the present date. REQUEST FOR PRODUCTION NO. 46: All written property inspection reports and property preservation reports related to the Subject Property, including all digital photographs or other images of the real property. REQUEST FOR PRODUCTION NO. 47: All bills and invoices for property inspections for the Subject Property and copies of the front and back of all checks in payment thereof or all confirmed wire transfers in payments thereof. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 10 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR PRODUCTION NO. 48: All invoices for each charge such as inspection fees, BPOs, appraisal fees, attorney fees, insurance, taxes, assessments or any expense which was charged to Plaintiffs’ mortgage account from the inception of this account to the present date. REQUEST FOR PRODUCTION NO. 49: A statement of the past due scheduled principal payments, together with interest thereon at the contract rate, past due taxes, hazard insurance, mortgage insurance premiums, late fees or charges, homeowners association dues, and any other assessments in connection with Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 50: An itemized statement of all of the filing fees, service fees, postage, advertising and publication expenses and reasonable attorney fees actually incurred with respect to any and all foreclosure proceedings regarding the Subject Property. Such attorney time records should be itemized by the date and nature of the service and the time devoted to each service. You should also produce the front and back of each and every canceled check in payment of each invoice for the charges described herein along with a copy of each respective bill, statement and invoice. REQUEST FOR PRODUCTION NO. 51: An itemized statement of all attorneys’ fees incurred at any time since the origination of Plaintiffs’ loan and describe the date and nature of all such services, attaching copies of all bills and invoices, and attach all canceled checks in payment thereof. Also, please attach all emails or electronic messages using NewTrak or any similar communication system regarding such fees and charges. REQUEST FOR PRODUCTION NO. 52: A complete and itemized statement from the date of the origination of Plaintiffs’ loan to the present of any property inspection fees, property preservation fees, broker opinion fees, appraisal fees, bankruptcy monitoring fees, or other similar fees or expenses related in any way to this loan. REQUEST FOR PRODUCTION NO. 53: A complete and itemized statement of any late charges to Plaintiffs’ loan from the date of the origination of the loan to the present. REQUEST FOR PRODUCTION NO. 54: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 11 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 A complete and itemized statement of any and all arrears including each month in which the default occurred, and the amount of each monthly default. REQUEST FOR PRODUCTION NO. 55: All invoices for each charge such as inspection fees, BPO s, appraisal fees, attorney fees, insurance, taxes, assessments or any expense which has been charged to Plaintiffs’ mortgage account from the inception of the account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 56: All checks used to pay invoices for each charge such as inspection fees, BPO s, appraisal fees, attorney fees, insurance, taxes, assessments or any expense which has been charged to Plaintiffs’ account from the inception of the account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 57: Each and every canceled check, draft or debit notice issued for payment of closing costs, fees and expenses, listed on any and all disclosure statements including, but not limited to, appraisal fees, inspection fees, title searches, title insurance fees, credit life insurance premiums, hazard insurance premiums, commissions, attorney fees, points, etc., on Plaintiffs’ account. REQUEST FOR PRODUCTION NO. 58: All invoices and detailed billing statements from any law firm or attorney that has billed such fees that have been assessed or collected from Plaintiffs’ account from the inception to the present date. REQUEST FOR PRODUCTION NO. 59: All agreements, contracts and understandings with vendors that have been paid for any charge on Plaintiffs’ account from the inception of the account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 60: All property inspection reports, appraisals, BPO s and reports done on the Subject Property. If none, state “none”. REQUEST FOR PRODUCTION NO. 61: All documents that reflect or relate to fees, commissions or other payments made to anyone in connection with Plaintiffs’ loan, including but not limited to, contracts, bills, cancelled checks and other back-up documentation for such payment. REQUEST FOR PRODUCTION NO. 62: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 12 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All documents relating to any fees, commission or payments received by YOU in connection with Plaintiffs’ loan. REQUEST FOR PRODUCTION NO. 63: All bills and invoices for property inspections for the Subject Property and copies of the front and back of all checks in payment thereof or all confirmed wire transfers in payments thereof. REQUEST FOR PRODUCTION NO. 64: Any and all invoices and detailed billing statements from any law firm or attorney that has billed fees that have been assessed to or collected from Plaintiffs’ account from the inception to the present date. REQUEST FOR PRODUCTION NO. 65: All telephone log sheets, internal memoranda, notes or other documents prepared or reflecting activity on Plaintiffs’ account in connection with his loan transaction. REQUEST FOR PRODUCTION NO. 66: Each and every check issued or received in connection with Plaintiffs’ loan. REQUEST FOR PRODUCTION NO. 67: All payment receipts, checks, money orders, drafts, automatic debits and written evidence of payments made by Plaintiffs or others on Plaintiffs’ account. REQUEST FOR PRODUCTION NO. 68: A complete and itemized statement of the loan transactional history from the date of the origination of Plaintiffs’ loan to the present including, but not limited to, all receipts by way of payment or otherwise and all charges to the loan in whatever form. This history should include the date of each and every debit and credit to any account related to this loan, the nature and purpose of each such debit and credit, and the name and address of the payee of any type of disbursement related to this account. REQUEST FOR PRODUCTION NO. 69: All checks and/or wire transfers to any party issued from funds received from any party in connection with Plaintiffs’ mortgage loan. REQUEST FOR PRODUCTION NO. 70: A complete and itemized statement from the date of the origination of Plaintiffs’ loan to the present of any and all debits and credits to any suspense accounts or any other suspense account entries related in any way to his loan. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 13 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR PRODUCTION NO. 71: All digital and numerical codes associated with the loan transaction history for Plaintiffs’ loan along with all definitions associated with each such code so as to make the history legible and understandable. Also, state the name of the software system YOU use, the version, and the name and address of the software provider. REQUEST FOR PRODUCTION NO. 72: All account servicing records, payment payoffs, payoff calculations, ARM audits, interest rate adjustments, payment records, transaction histories, account histories, accounting records, ledgers, and documents that relate to the accounting of Plaintiffs’ account from the inception of his account to the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 73: All payment receipts, checks, money orders, drafts, automatic debits and written evidence of payments made by Plaintiffs’ or others on his account. If none, state “none”. REQUEST FOR PRODUCTION NO. 74: Each and every canceled check, draft or debit notice issued for payment of closing costs, fees and expenses listed on any and all disclosure statements including, but not limited to, appraisal fees, inspection fees, title searches, title insurance fees, credit life insurance premiums, hazard insurance premiums, commissions, attorney fees, points, etc. If none, state “none”. REQUEST FOR PRODUCTION NO. 75: All escrow analyses conducted on Plaintiffs’ account from the inception of the account until the present date. If none, state “none”. REQUEST FOR PRODUCTION NO. 76: All MORTGAGE ELECTRONIC REGISTRATIONS SYSTEMS, INC. (MERS) documents related to Plaintiffs’ loan, including the MIN number. REQUEST FOR PRODUCTION NO. 77: Any and all communications and/or documents evidencing instructions and/or directions that YOU received concerning the non-judicial foreclosure of the Subject Property from any and all other entities. REQUEST FOR PRODUCTION NO. 78: Each and every assumption, modification, written assurance or substitution agreement related to any document requested herein. REQUEST FOR PRODUCTION NO. 79: PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 14 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 All written acknowledgments for the receipt of all documents related to Plaintiffs’ mortgage loan executed by YOU. REQUEST FOR PRODUCTION NO. 80: All endorsements to Plaintiffs’ original note, including all such endorsements from the date of origination to the present, so as to show a complete chain of endorsements from the originator to the person so endorsing to THE HOLDERS OF THE TERWIN MORTGAGE TRUST 2007-QHL1 ASSET-BACKED SECURITIES, SERIES 2007-QHL1, WITHOUT RECOURSE trust. REQUEST FOR PRODUCTION NO. 81: Plaintiffs’ original deed of trust, with evidence of recording thereon. REQUEST FOR PRODUCTION NO. 82: All documents or records maintained by any duly appointed custodian who accepted delivery or acknowledged receipt of any document referred to herein on behalf of YOU. REQUEST FOR PRODUCTION NO. 83: All documents in the "mortgage file" for this loan in YOUR possession or any designated custodian. REQUEST FOR PRODUCTION NO. 84: All original intervening receipts of delivery and acceptance of each assignment of Plaintiffs’ mortgage loan showing a complete chain of such receipts from the originator to the person accepting the document for YOU. REQUEST FOR PRODUCTION NO. 85: The COMMITMENT TO PURCHASE FINANCIAL INSTRUMENT and SERVICER PARTICIPATION AGREEMENT for the HOME AFFORDABLE MODIFICATION PROGRAM under the EMERGENCY ECONOMIC STABILIZATION ACT OF 2008 entered into by YOU and the United States government. REQUEST FOR PRODUCTION NO. 86: Any and all loan modification agreements entered into between Plaintiffs and Defendants. If none, state “none.” REQUEST FOR PRODUCTION NO. 87: YOUR entire file related to Plaintiffs. REQUEST FOR PRODUCTION NO. 88: YOUR entire file related to Plaintiffs’ mortgage loan. PLAINTIFF’S FIRST SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO SLS 15 123456789 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REQUEST FOR PRODUCTION NO. 89: Any and all documents which relate to, refer to or evidence the sale of the Subject Property. REQUEST FOR PRODUCTION NO. 90: Any and all documents which relate to, refer to or evidence the accounting with regard to debts owed, amounts paid and future interests as a result of the non-judicial foreclosure sale of the Subject Property. REQUEST FOR PRODUCTION NO. 91: Any and all documents which relate to, refer to or evidence the marketing of the Subject Property, after the non-judicial foreclosure of the Subject Property. REQUEST FOR PRODUCTION NO. 92: Any and all documents which relate to, refer to or evidence the non-judicial foreclosure of the Subject Property. REQUEST FOR PRODUCTION NO. 93: Any and all documents identified in YOUR responses to Plaintiff’s First Set of Form Interrogatories. DATED: LAW OFFICES OF CAMERON H. TOTTEN By: ____________________________ Cameron H. Totten Attorney for Plaintiffs

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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